GUIDELINE SERIES OAQPS NO. 1.2-011 DRAFT GUIDELINES FOR DETERMINING THE NEED FOR PLAN REVISIONS TO THE CONTROL STRATEGY PORTION OF THE APPROVED STATE IMPLEMENTATION PLAN 3OC US. ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina ------- OAQPS 1.2-011 GUIDELINES FOR DETERMINING THE NEED FOR PLAN REVISIONS TO THE CONTROL STRATEGY PORTION OF THE APPROVED STATE IMPLEMENTATION PLAN DRAFT Analysis and Reports Section Standards Implementation Branch Control Programs Development Division Office of Air Quality .Planning and Standards November 30, 1973 ------- TABLE OF CONTENTS I. Introduction 1 II. Responsibilities in Implementing Plan Revisions. ... 3 III. Procedures for Determining Whether a SIP/Control Strategy Needs to be Revised 5 A. Identification of Problem Air Quality Control Regions 5 B. Evaluation of Data 7 C. Analysis of Control Strategy 10 D. Reporting of Results 13 IV. Procedures for Requiring Plan Revisions. . v 14 A. Plan Revision Documentation. 14 B. Notification and Concurrence 15 C. Notification of State 15 D. Plan Submittal 17 ------- I. Introduction Section 110(a)(2)(H) of the Clean Air Act, as amended requires that State Implementation Plans (SIP's) "provide for revision, after public hearings, of such plan (1) from time to time as may be necessary to take account of revisions of such national primary or secondary ambient air quality standard or (2) the availability of improved or more expeditious methods of achieving such primary or secondary standard; or (3) whenever the Administrator finds on the basis of information available to him that the plan is substantially inadequate to achieve the national ambient air quality primary or secondary standard which it implements." While the Act specifically identifies three (3) reasons why SIP's can and must be revised, this guideline deals mainly with plan revisions to the control strategy portion of the SI? which are deemed necessary on the basis of information available to the Agency which indicates the approved SIP/control strategy is inadequate to attain the national standard it implements. While the reasons for requesting a revision may be different, the administrativa procedures for requesting a revision under each of the three cases is the same. EPA must exercise good judgement in determining whether the control strategy portion of an approved SIP is inadequate to achieve national standards on a timely basis. It should be the Agency's policy to request such plan revisions only where they are clearly necessary. Frequent revisions, particularly where they affect emission control requirements, are undesirable in that they confront source owners with a "moving target." In an attempt to assist in identifying those Regions that may need plan revision, the Standards Implementation Branch (SIB) of the Control Programs ------- 2 Development Division, Office of Air Quality Planning and Standards, has developed a PLAN REVISION MANAGEMENT SYSTEM (PRMS) which compares actual measured air quality levels, submitted by States as part of their quarterly reports, with projected emission reductions required by the adopted emission limitations contained in the approved SIP. The system is capable of moni- toring the progress in each AQCR and when ambient air quality levels do not follow the anticipated reductions, the region will be flagged as a "potential problem region." Further investigation by regional personnel will be necessary prior to the determination of whether a plan revision is needed. The majority of the information that will be needed to formulate the decision as to whether the control strategy is inadequate to achieve the national standards will be obtained from the quarterly and semiannual reports (40 CFR 51.7, Report, August 3, 1973). Of course, other informa- tion such as the Quarterly Trends Report, daily contacts with State and local agencies, compliance information (see enclosure 1), etc., should also be used in the determination. Air quality data will be the key indicator of a "potential problem region," as measured air quality will be the real indicator of attainment of the NAAQS. However, emission data, enforcement and compliance information, etc. must be reviewed to determine the adequacy of the control strategy to attain the national standard in relation to the measured air quality levels. \ j This guideline sets forth (1) the procedures for determining when a revision to the control strategy portion of the SIP is necessary (2) the procedures for notifying the State that a plan revision is necessary and (3) the responsibilities of headquarters and regional personnel in ------- 3 implementing the:e procedures. II. Responsibilities in Implementing Plan Revisions In cases where revisions to the control strategy are necessary because new information indicates that the approved control strategy is inadequate to attain the national standards, the Regional Office will be primarily responsible to review available information and recommend any action, if appropriate, to call for a plan revision. Recently, in response to a request by the Assistant Administrator for OAWP, the Administrator delegated his authority to request a plan revision to the Regional Administrators'through EPA Order 1270.5 (see enclosure). In cases where the requested revision would significantly affect emission control regulations, or the enforcement thereof, Regional Administrators should obtain the concurrence of the Deputy Assistant Administrator for Air Quality Planning and Standards and the Deputy Assistant Administrator for General Enforcement prior to request- ing that the State make the revisions. Further, where the requested revision would have significant national policy implications or would establish a significant precedent (the first time a substantial type of action is taken anywhere), the above Deputy Assistant Administrators' concurrences should be requested. Insofar as other revisions are concerned, Regional Administrators should simply notify the above Deputy Assistant Administrators of requests trade. OAWP/OAQPS will provide overall assistance to the Regions in this area. A Plan Revision Management System is in operation which will provide a review of the air quality data received from each State and local agency and identify those Regions where it appears adequate progress is not being made in attaining the air quality standards as provided in the ------- implementation of the SIP. In addition, OAQPS wi.ll publish the Quarterly Trend Reports, Quarterly Air Quality Summary Statistics and the Annual National Emission Report. These reports will serve to assist the Regional Offices; as the Regional Offices will have the primary responsi- bility for determining whether a plan revision is needed. Once tne plan revision has been submitted by the State, the Regional Offices (as outlined in the September 14, 1972, Sansom/Quarles memo of understanding, as revised in 1.2-005 (revised) of the OAQPS Guideline Series) are further responsible to review, to recommend approval/dis- approval and promulgation and to prepare the Federal Register package associated with any measures which have been determined to be necessary to assure that the national standards will be achieved. Headquarters (OAWP/OAQPS and OEGC/DSSE) will provide technical and policy assistance to assure national uniformity on various issues insofar as appropriate. Headquarters will also have the responsibility to review and to concur or nonconcur with the recommended action for each revision. The Agency responsibilities are somewhat different in those cases where plan revisions are necessary to take account of new or revised national standards. In this case, OAWP has the primary responsibility of preparing and publishing in the federal Register (1) the new or revised national standards and (2) specific guidelines en what actions States need to take to develop, adopt and submit an approvable plan to implement the new or revised standard. In general, all States will be required to subnit a plan for a new national standard or will be required to revise their existing SIP's to consider a revised national standard. After OAWP has published guidelines for the dc-velopmont of approved SIP's, ------- the Regional Offices are then responsible to assist States in the development of SIP's etc. In situations where the SIP regulations (40 CFR Part 51) are modified in such a way as to affect the control strategy requirements (such as the recent action in relation to maintenance of standards (40 CFR 51.12, June 18, 1973) and the pending action in relation to tall stacks) OAWP and Regional Office responsibilities are identical to those described for a new or revised standard. III. Procedures for Determining Whether a SIP./Control Strategy Meeds to Be Revised A. Identification of problem air quality control regions It is difficult to develop comprehensive guidance on exactly how to detemine whether a control strategy will need to be revised. While there may be a few situations where it is obvious that a plan revision is necessary, in general it will be a difficult task to determine that a plan is inadequate to attain the standards prior to the established attainment date. The problem is to determine whether AQCR's are progressing satisfactorily in relation to the emission limi- tations contained within the SIP. To this end, a Plan Revision Manage- ment System (PRMS) was developed to track the progress being made by States in implementing their SIP. PR/MS provides a means for effectively combining information contained in SAROAD (air quality) NEDS (source emissions), and CDS (enforcement and compliance information) to compare measured progress against expected progress. This system is designed to monitor the progress of actual air quality levels, obtained from the quarterly reports, in relation to the anticipated air quality reductions which should occur as a result of ------- 6 compliance with approved emission limitations. If the difference between the observed and projected air quality levels exceed certain specified limits, then the site is "flagged" as a "potential problem." A number of flagging levels or tolerance limits are incorporated in the system to indicate that the site either has acceptable progress or is having a minor, major or significant problem toward attainment of the NAAQS. The tolerance limits were developed through the application of statistical quality control techniques which allow for the many variables associated with measured air quality concentrations. (See Figure 1) Once a "potential problem region" is identified, OAQPS will notify the appropriate Regional Office. This will be done on a semiannual basis. The Regional Office will be responsible for investigation and further assess- ment of the problem. The Regional Office should also report their findings to OAQPS indicating the action they have taken or plan to take. . While the PRMS will provide a mechanism to identify "potential problem regions" from an analytical point of view, the Regional Offices should be more intimately aware of the status of Regions within their States. Thus, the Regional Offices may be aware of other AQCR's not currently being analyzed by the PRMS which should be reviewed to determine if the plan is adequate to attain the NAAQS by the specified data for attainment. Currently, there are 17 AQCR's contained in the PRMS. An additional 50 Regions will be included in the system by January 1974. The additional 50 Regions that were selected for analysis were based on recommendations of the Regional Offices as to those AQCR's which should be reviewed to insure that adequate progress is being made toward attainment of the standards. By mid-1974, 50 more AQCR's are scheduled to be included in the PRMS. Thus, by July 1974, 117 Regions will be analyzed. The Regional Offices should ------- Figure 1 PLAN REVISION MANAGEMENT SYSTEM Particulate Matter Emissions (1000 tons/year) 150 100 50 1970 1971 1972 1973 1974 1975 1976 1977 Air quality (yg/m3) 150 100 50 0 Tolerance limits Projected air quality 1970 1971 1972 1973 1974 1975 1976 1977 Calendar Year "Measured air quality Step #1 Calculation of emission reduction (NEDS, Emission Regulations) #2 Review of compliance dates (SIP, CDS, Emission Regulations) #3 Projection of air quality #4 Establishment of tolerance limits or boundaries #5 Measured air quality trend (SAROAPN ------- indicate to OAQPS those AQCR's that they believe should be reviewed to determine the possible need for plan revisions. It is understood that air quality levels throughout an AQCR are highly variable and that each monitoring site within the region must have levels at or below the national standards by the specified date for attainment to be in compliance with the Act. The PRMS analyzes all monitoring sites within SAROAD for the particular AQCR in question to determine if adequate progress is being made. Thus, the system is capable of defining the problem on a much smaller scale than the entire AQCR. While most of the'region may be showing adequate progress, a few sites, located in areas of maximum concentration, may be deviating from the desired air quality levels. Review of these sites will allow the Agency to take a much closer look at the real problem areas. Because the R.O. may only be required to review a very few problem sites, more effort can be placed upon those areas within an AQCR which appear to-.be having the most difficulty 'in attaining the standards. It is believed'at ^his time that it will not be necessary in most cases to require a major plan revision for an entire AQCR. The revision or additional action can be tailored to a minimum number of sources to give the maximum amount of benefit toward attainment of the standards. Thus, a review to determine the adequacy of the progress for a region should be done on a site by site basis. B. Evaluation of Data The review of problem monitoring sites should include three basic items. Is the data valid? What were the meteorological conditions during the reporting period? Is the control strategy for the region adequate to correct the problem at this site? ------- 8 The validity of the air quality data is the major item in the review of potential problem sites. Monitoring and Data Analysis Division, OAQPS is preparing several guidelines to assist in the validation of air quality data. (See enclosure #3) While EPA should generally be confident of the validity of the air quality data submitted by State and local agencies, it is also necessary to review the validity of specifid data especially those data which indi- cate the need for plan revision. The Regional Office should refer to the guidelines mentioned above for the specific items that must be reviewed to verify the data. However, basically these steps should include: a. Discussion with the State or local agency to verify their confidence in the submitted data. b. Determination that the State or local agency laboratory or quality control procedures are adequate. c. Determination that the sampling instrument that was used to measure the data was calibrated and operating properly. d. Review the strip chart or other record of the measurement to verify the reported values. e. Determine if the sampling method by which the data were measured is reliable and in accordance with the specified reference method or equivalent. f. In certain cases, it may be necessary to visit the monitoring site to determine its representativeness. Does it meet EPA criteria for location of ambient monitors? Are surrounding structures or buildings causing unusual air flow patterns near the sampler? Is the sampler influenced by emissions from the chimney or incinerator of the building on which the sampler is located, or is the sampler ------- on a building surrounded by a heavily used unpaved parking lot? In summary, is the data collected by the site representative of air quality levels and should the data collected at the site- be used as a basis for developing a control strategy? The last item in data validation is very important. All problem sites should be reviewed in detail. . It is suggested that each problem site be visited to determine its representativeness and to see what local sources, if any, may be causing the major impact upon a particular receptor. If after a review of the above items it is determined that the air quality values are valid then a review of the meteorological conditions should be conducted. If the frequency and duration of inversions and stagnations were unusually high, air quality could be higher than normal. Unusually warm or cold weather will result in a change in fuel use which may increase ambient levels above normal. Snow or ice storms may be assoc- iated with excessive sanding or salting of streets, and thus increase particulate matter concentrations. Long periods of dry weather may also .increase the parti cul ate matter concentrations. . The review of air quality data should also attempt to identify if high concentrations were caused by unusual, events, such as local construc- tion or demolition activity, fires or perhaps control equipment malfunction or shut-down which could temporarily cause abnormally high ambient concen- trations. Data collected during abnormal situations should not be used as a basis for requiring plan revisions. If data are determined to be "abnormal" or invalids or that they represent unusual circumstances, such data should be reported so that the SAROAD data bank users are properly notified of these conditions. ------- 10 After the air quality data has been validated and the unusual meteor- ological conditions have been investigated, the Regional Offices should make an attempt to obtain the very latest air quality concentrations for the site in question. Because of the lag in processing the air quality data from quarterly reports, the SAROAD system may be as much as two to four quarters behind the current air quality levels; therefore, the Regional Offices are encouraged to obtain the very latest data possible for the sites in question and submit this data to the PRMS so that an updated analysis can be performed to assure that we have the latest data possible upon which to base the analysis for determining adequate progress. The PRMS system has been developed with the capability to temporarily accept selected data independent of the SAROAD system so that the best and most up-to-date information is available for the Regional Office review. Attempts should be made by the Regional Offices to see that data from those monitoring sites with potential problems receive the highest priority by attempting to have the data from those sites reduced and submitted to SAROAD as quickly as possible. C. Analysis of Control Strategy With the addition of the latest air quality data, a comparison of the trends in air quality levels at the site in question, with the air quality trends noted at other sites within the Region (State, city or other area where comparable results should exist) should be made. If the increase or decrease is significantly different than at the other sites, it would appear that a localized problem exists. For the purposes of this guideline, let us assume that the site in question is out-of-line with other ambient monitors in a region. In this ------- 11 case, it is recommended that a review of the emission data and compliance status of sources within the immediate vicinity of the site in question (say within a 1 to 3 mile radius—particulate matter and sulfur dioxide only, CO and oxidant would require much large area) be made. Points to consider include: a. Are some sources presently uncontrolled? If so, are there control regulations with which these sources must ultimately comply? If not, do these sources impact sufficiently on the site to warrant a recommendation for a plan revision to require further emission limitations on these sources? b. If the sources reviewed in (a) have applicable regulations that they must adhere to at some later date, is the anticipated erris- sion reduction adequate to reduce ambient levels to below the standard? c. Do the sources reviewed in (a) have applicable emission limita- tions they must presently comply with? Are the sources in compliance with the regulations? If so, will additional emission reductions be needed to provide for the attainment of the national standard? If the sources are not in compliance with the emission limitation, is the source on a compliance schedule? Should EPA/ State enforcement action be initiated against the source? d. Have the sources in the vicinity of the site in question increased significantly? Is a plan revision necessary to compensate for increases in emissions? What action is needed in relation to assuring that the State adequately considers ambient standards prior to their providing approval to construct new sources? ------- 12 Sometime during the investigation of potential problems there should be a review of the technique originally utilized for the AQCR to correlate the reduction in emissions with those in air quality levels. Such an analysis was suggested in (a) and (b) above. There are a number of approaches available, each providing various degrees of accuracy which can provide a relationship betv/een emission reductions and resultant ambient air quality. The selection of the appropriate method for determining this relationship depends upon the Regional Office resources available to address the problem. Basically, these methods include: a. Simple Rollback or proportional model which assumed that as emis- sions are reduced or "rolled back" by one percent there is a corresponding one percent reduction in ambient levels. This is a gross method of estimating the degree of emission reduction necessary to meet air quality goals and is by no means absolute. Most States used this method to develop their original SIP's because it is relatively simple and does provide a gross estimate of the degree of a problem in a Region. The method is deficient in- that it does not consider meteorology, spatial distribution of sources, nor the height of emission release; three important factors which influence ground level concentrations. It is recommended that in determining the need for a plan revision that a more detailed approach be utilized in defining the relationship between emission reductions and air quality. b. Modified Rollback procedures have been recently developed by the Monitoring and Data Analysis Division, OAQPS. These procedures provide a more sophisticated approach to the relationship of emissions to air quality. This procedure considers meteorology, ------- 13 spatial distribution of sources, and the height of emission release. The modified rollback provides a more accurate definition of the problem but also requires mere rofined omission data arid more nranpov/er. The procedure is applicable to an urban area (city center) problems. c. Diffusion Modelin? is the preferred predictive tool available in relating .emission to air quality duta. A number of diffusion mc'-iels (Air Quality Display ifod^l, AQDM, and t!,ie Implementation Planning Program, IPP) are available for defining urban situa- tions on an annual basis. Point source modsIs are also available for single source short-term (1 hr and 24 hr) situations. Diffusion modeling requires detailed emission, air quality and meteorological data to mathematically simulate the: emission/air quality relation- ship for a given region, Voile there are certain limitations which restrict the use of diffusion nodals (lack of data} severe topo- .. • ^ I':;[••:!! C Vc i' I •:* i. i 'j\\'i ; •.. «..'w . / * '.::<: ..'.; 1.1 ,'•.> U C.'»-:,';-• jj ;Xi V i--J'-.' >.i:'o IK..}!, i:\i'.\ , ••• able approach to predict resuVLir.g ch'ibient levels caused by the application of emission "h'mitatioiis 0,1 emission sources. Enclosure #4 provides a list of those diffusion models which are readily available to the Regional Office through the Tirr.e Sharing Option (TSO) computer facility. D. Reporting of Results The Regional Office will be notified 30 days after the semiannual report is due (February 15, August 15) of those potential problems and should report on the status of their investigation within 30 days prior to the date due for the next semiannual report. It should be noted that the above investigation of potential problem sites may require more than just one semiannual reporting period to complete the investigation. ------- 14 Thus, the results reported to OAQPS for inclusion into the Adminis- trators SIP Status Report may include several different recommended actions. These include: 1. Data determined to be invalid—work proceeding to correct and validate data. 2. Unusual meteorological conditions existed at the time and more recent data indicated adequate progress. 3. No action, minor problem identified and resolved. 4. No action, new projected air quality curve should be developed to better define the trend in estimated air quality. 5. No action, pending further study—inconclusive or marginal analysis, too early to determine if problem exists. 6. More effective implementation of new source review procedures to restrict growth in certain areas is needed. 7. EPA/State enforcement action is necessary 8. Plan revision is needed. Procedures on how to require a plan revision for those cases where the need has been identified are described in Section IV. IV. Procedures for Requi ring PI an Reyi sions . If a revision to the control strategy is determined to be needed, the following actions are necessary: A. Plan Revision Documentation The Regional Office should document the reason why the plan revision is necessary, providing as much detail as possible on the discovery analysis performed to determine the need for the revision and identify, if possible, what source(s) or source categories should ------- 15 be considered under the plan revision. While it is hoped that , the approved SIP will be adequate to attain the national standard on a region-wide basis, it is highly likely that portions of some AQCR's ("subregions") will need further controls to achieve the standards. Therefore, it is proper and necessary to identify those sources which may need to be considered when developing the plan revision. This analysis should be discussed with the State and local agencies involved. B. Notification and Concurrence Where the requested revision would significantly affect emission control regulations, or the enforcement thereof, the Regional Offices should obtain the concurrence of the Deputy Assistant Administrator for Air Quality Planning and Standards and the Deputy Assistant Administrator for General Enforcement prior to officially requesting a plan revision by the State. Further, where the requested revision should have significant national policy implications or would establish a significant precedent, the above Deputy Assistant Administrators' concurrence should be sought. In so far as other revisions are concerned, the Regions should simply notify the above Deputy Assistant Administrators of plan revision requests that have been made. C. Notification of State The Regional Offices should confer with the State and/or local agencies involved and advise them of the need for a revision. The Regional Administrator should officially notify the State (Governor) that a. revision is necessary*. The notice should identify the following: (1) Why the plan revision is necessary *Thc issue of whether this should be done by letter or Federal Register notice will be discussed in a separate memo rand urn. - ------- 16 (2) What appears to be necessary to correct the deficiency i.e., what sources appear to cause the need for further controls (3) What other portions of the SIP must be revised as a consequence of the control strategy revision. These may include: (i) Section 51.11 Legal authority-- especially if transportation controls are deemed necessary (ii) Section 51.15 Compliance schedules must be provided if new control regulations are adopted. The negotiated schedules must be submitted at the time of submittal of new regulations. However, if the regulation is immediately effective, then the schedules can be submitted as a plan revision itself. (iii) Section 51.17 Air Quality Surveillance — The increase of ambient levels may indicate a more widespread problem than anticipated. More ambient sampling may be needed to define the extent of the. problem and monitor progress. (iv) Section 51.21 Intergovernmental cooperation -- This section may need to be revised if the State delegates new responsibility to other State or local agencies to carry out portions of the plan. (v) Section 51.20 Resources - New control regulations may require additional resources for enforcement purposes. Such information should be reported with the plan revision. ------- 17 (vi) Section 51.10 General requirements - The control regula- tions submitted as part of the plan revision may indicate the need for a change in the date of attainment of the national standard. Plan revisions designed to attain the primary standard which require more stringenet controls than that which is reasonably available, and which are more restrictive than the original SIP may justify the need for an extension of up to two years (section 51.30). One year postponements, 40 CFR 51.32 (revised June 19, 1973) may also be utilized. It should also be noted that plans to attain the national secondary standard must do so within a "reasonable time." (4) The time period for submission of the revision to the Agency (Section 51.6(b), Revision) states that 'the plan shall be revised within 60 days following notification by the Adminis- trator, or by such later date prescribed by the Administrator after consultation with the State." Since a control strategy will need to be developed and a compliance schedule determined and then have the regulations subjected to a public hearing and be adopted, it appears that four to six months and perhaps longer will be needed in most cases to revise the control strategy portion of the plan. (5) The plan revision must be submitted in accordance with the pro- visions of 40 CFR 51.4, Public hearings and 51.6, Revisions. D. Plan Submittal Once the plan revision is submitted by the State, the Agency procedures outlined in the Sansom/Quarles memo of understanding of September 14. 1972, as revised by OAQPS No. 1.2-005A, of the Guideline Series govern the review and approval process. Because of a recent court decision, however, the ------- 18 Agency must now publish, in the Federal Register, the fact that a new or revised SIP has been subm'tted to the Agency and that the public has 30 days to comment on the new plan. These procedures will apply also to all regulatory plan revisions. ------- OUTLINE OF RESPONSIBILITY Air Quality Data From/ States / Regional Of fi ces ther AQCR's RO Notified of Problem Adequate Progress No Action Within Normal Limits iRO Review For i [Potential j Problem Validate air uali aag/ p Data Revised Report to OAQPS Results for Report to Administrator RO nvastigate nd resolve ------- Enclosure #1 ------- Enclosure #1 Additional Technical Publications to Assist in Regional Office Investigation of the Need for Plan Revisions 1. AP 78: Guide for Air Pollution Episode Avoidance 2. AP 98: Air Quality Surveillance Networks i 3. APTD 0736: Field Operators Guide for Automatic Air Monitoring Equipment 4. APTD 1085: Air Quality Data Handling System Users Manual 5. APTD 1347: Guidelines for Technical Services of a State Air Pollution Control Agency 6. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance Program - Photochemical Oxidants 7. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance Program - Carbon Monoxide 4 8. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance Program - Suspended Particulate Matter ------- MDAD NADB Reports a. NEDS SAROAD quarterly reports b. Quarterly summary ststisties air quality data c. National Emission Report (Annual) d. Site file directory - air quality monitoring (annual) e. ISO/direct request using standard computer program MRB a. b. Trends Report (Quarterly) Special analysis reports (quarterly) Reporting high measurement regions DSSE - (CDS/KAPINS) a. Semiannual questionnaire used to update CDS b. Region by region statistical output - data"summary by city/county/ region/state, etc. (percent in compliance, etc.) c. Source ID report - Basic Source Data d. ' Future schedule summary e. Geographic locations f. Action summary report g. Status summary report h. Source action summary j. Overdue action report GAD' Must be some reporting but '.-liable to identify specific items SIB a. Guidelines for dcmer ^.i.-j the need for a plan revision b. RTI manual for P.I'iS analysis C. Protocol for submitting new data and results of PRMS to R.O. ------- Enclosure #2 ------- ENVIRONMENTAL [PROTECTION ORDER AGENCY I 1270.5 October 15, 1973 DELEGATIONS OF AUTHORITY - AIR AND WATER PROGRAMS DELEGATION OF AUTHORITY TO REQUEST STATES TO REVISE STATE IMPLEMENTATION FLANS 1. PURPOSE. This Order delegates to the Regional Administrators the authority to request States to revise State Implementation Plans under Section 110(a)(2)(H)(ii) of the Clean Air Act. 2. BACKGROUND. Section 110(a)(2)(H)(ii) of the Clean Air Act provides for the revision of State Implementation Plans (SIP's)•"whenever the Administrator finds on the basis of information available to him that the plan is substantially inadequate to achieve the national ambient air quality primary or secondary standard which it implements." In view of the emphases on utilizing regional offices in supervising the SIP's, a delegation of authority to the Regional Administrators uo request the revisions is in order. 3. DELEGATION. The Regional Administrators are delegated authority to perform the responsibilities indicated above within their respective regions. 4. LIMITATIONS. a. Revisions will be requested only when such revisions are clearly necessary. •» b. Where the requested revision would affect emission control regulations significantly, or the enforcement thereof, Regional Admin- istrators should obtain the concurrence of the Assistant Administrator for Air and Water Programs and the Assistant Administrator for Enforce- ment and General Counsel. c. Where the requested revision would have significant national policy implications or would establish a significant precedent, the concurrence of the aforesaid Assistant Administrators is required. Dist: Directives Distribution initiated by: AF ------- 1270.5 October 15, 1973 d. Insofar as other revisions are concerned, Regional Administrators should simply notify the two Assistant Administrators of requests made. e. This authority may not be redeles Russell E. Train Administrator ------- Enclosure #3 ------- Enclosure #3 Guidelines on Ambient Trend Monitoring Monitoring and Data Analysis Division 1. General guidelines for Regional Office monitoring programs PURPOSE: General summary of existing ambient trend monitoring guidelines 2. Guidelines for validation of Air Quality Data PURPOSE: Steps to insure valid data 3. Guidelines on interpretation of Air Quality Data as it relates to NAAQS. PURPOSE: Answer questions on how NAAQS and Air Quality is related 4. Guidelines for network design and instrument siting PURPOSE: Network design and instrument siting criteria 5. Guidelines for selection of air monitoring instruments. PURPOSE: Selection of instruments 6. Guidelines for evaluation of air quality trends PURPOSE: Trend evaluation 7. Guidelines for the evaluation of air quality data PURPOSE: Evaluation methodology 8. Guidelines for complex source monitoring 9. Evaluation of SIP monitoring requirements ------- Enclosure #4 ------- Enclosure # CATALOG OF PROGRAMS as of OG/01/73 APRAC - A short-term Urban Diffusion Model that calculates the automotive contribution to Carbon Monoxide. The model was developed by Stanford Research Institute (SRI). A 120 page manual is available on the model. HIWA'.Y - PTMAX - PTD/S PTMTP READT A model that calculates a pollutant concentration in the vicinity of a roadway. The model is self-documenting. An interactive program which performs nn analysis of the maximum, short-term concentration from a point source as a function of stability and wind speed. An interactive program which computes short-term concentrations downwind from a point source at distances specified by the user. An interactive program which computes, at multiple receptors, short term concentrations resulting from multiple point sources. ------- |